HomeMy WebLinkAbout20143734.tiff 4 CDPHHE COLORADO
DP
CO Department of Public
Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St RECEIVED
PO Box 758
Greeley, CO 80632
DEC 0 1 2014
November 24, 2014 WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On November 26, 2014, the Air Pollution Control Division will begin a 30-day public notice period for
Noble Energy, Inc. - Wells Ranch EcoNode Sec-25. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the date the public notice is published. Please send any comment regarding this public notice to the
address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
i 7;
J
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
,�i"'/ L A. ?y.
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ( / r', °oi
John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer 1,K.; ,?.
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/2-S - /4 Ct: t-FPLx1, 0L /2/2 2014-3734
CDPHE Public Notice Of A Proposed Project
Ark 1 Or Activity Warranting Public
CO Comment
Website Title: Noble Energy, Inc. - Wells Ranch EcoNode Sec-25 - Weld County
Notice Period Begins: November 26, 2014
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Noble Energy, Inc.
Facility: Wells Ranch EcoNode Sec-25
Oil and gas exploration and production facility
SWNW Section 25, T6N, R63W
Weld County
The proposed project or activity is as follows: Existing oil and gas exploration and production facility adding
a separator flare and permitted produced water tanks.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permits 12WE2094, 12WE2317,
13WE1098 and 14WE0968 have been filed with the Weld County Clerk's office. A copy of the draft permit
and the Division's analysis are available on the Division's website at
https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division wilt receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
L� COLORADO
D F STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE:(303)692-3150 « +�'
•+=8'/6 t
CONSTRUCTION PERMIT
PERMIT NO: 1 2 E2094
- Issuance 1
DATE ISSUED:
ISSUED TO: Noble Energy, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Wells Ranch EcoNode—Sec. 25, located in the SWNW of
Section 25, Township 6 North, Range 63 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
PW Six (6) above ground 500 bbl atmospheric produced water storage
415817940 009 tanks. Emissions from these tanks are controlled by an enclosed
flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN
THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
https://www.colorado.00v/pacific/cdphe/other-air-permitting-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control Commission
(AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the
permit.
2. Within one hundred and eighty days(180)after issuance of this permit, compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i)does not commence construction/modification or operation of this source within 18
months after either the date of issuance of this construction permit or the date on which such
AIRS ID: 123/9586 Page 1 of 11
Produced Water Tank SM/MVersion 2012-1
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construction o as s h in the permit application
associated with this permit; (ii)discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline per Regulation No. 3,
Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification,with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point NO, VOC CO Emission Type
PW 009 -- 3.3 --- Point
415817940
See'Notes to Permit Holder"for information on emission factors and methods used to calculate lint.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
6. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
PW 009 Enclosed flare VOC and HAPS
415817940
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following processing rate as listed below.Annual records
of the actual processing rate shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Reference: Regulation 3, Part B,
II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment Point
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ID
PW 009 Produced water throughput 500,000 BBL/yr
415817940
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
8. Records shall be kept in either an electronic file or hard copy provided that they can be
promptly supplied to the Division upon request. All records shall be retained for a
consecutive period of three years.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
10. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section
II.A.1. &4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
12. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). These requirements include, but are not limited to:
XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile
organic compounds to comply with Section XVII, it shall be enclosed, have no visible
emissions during normal operations, and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion
device, or by other convenient means approved by the Division, determine whether it
is operating properly. The operator shall comply with all applicable requirements of
Section XVII.
XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an
operational auto-igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C
emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6)tons per year based on a rolling twelve-month
total must operate air pollution control equipment that achieves an average
hydrocarbon control efficiency of 95%..If a combustion device is used, it must have a
design destruction efficiency of at least 98% for hydrocarbons.
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XVII.C C e ion 1.b. must be achieved by
May 1, 2015.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio,
visual,olfactory("AVO")and additional visual inspections of the storage tank and any
associated equipment (e.g. separator, air pollution control equipment, or other
pressure reducing equipment) at the same frequency as liquids are loaded out from
the storage tank. These inspections are not required more frequently than every
seven (7)days but must be conducted at least every thirty one(31)days. Monitoring
is not required for storage tanks or associated equipment that are unsafe,difficult,or
inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual
inspections must include, at a minimum: -
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to
ensure that it is operating, including that the pilot light is lit on combustion
devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that
the valves for the piping from the storage tank to the air pollution control
equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the equipment
must be immediately shut-in to investigate the potential cause for smoke and
perform repairs, as necessary, or EPA Method 22 must be conducted to
determine whether visible emissions are present for a period of at least one
- (1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to
monitor, the owner or operator is not required to monitor such equipment until it
becomes feasible to do so.
XVII.C.2.Capture and monitoring requirements for storage tanks that are fitted with air
pollution control equipment as required by Sections XII.D. or XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air
pollution control equipment, and must operate without venting hydrocarbon emissions
from the thief hatch (or other access point to the tank) or pressure relief device
during normal operation, unless venting is reasonably required for maintenance,
gauging, or safety of personnel and equipment. Compliance must be achieved in
accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a
documented Storage Tank Emission Management System("STEM")plan to identify,
evaluate, and employ appropriate control technologies, monitoring practices,
operational practices, and/or other strategies designed to meet the requirements set
forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as
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Color Depa e f bli Health and Environment
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necesD c Own operators are not required
to develop and implement STEM for storage tanks containing only stabilized liquids.
The minimum elements of STEM are listed below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices,
operational practices, and/or other strategies; procedures for evaluating
ongoing storage tank emission capture performance; and monitoring in
accordance with approved instrument monitoring methods following the
applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in
Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved
instrument monitoring method in accordance with the following schedule:
XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply with
the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015.
Approved instrument monitoring method inspections must begin within ninety
(90) days of the Phase-In Schedule in Table 1, or within thirty (30) days for
storage tanks with uncontrolled actual VOC emissions greater than 50 tons
per year.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the Inspection
Frequency in Table 1.
Table 1 — Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In Schedule
Uncontrolled Actual VOC Monitoring Method
Emissions (tpy) Inspection Frequency
> 6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult,or inaccessible to monitor,as
defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the
selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C.
must maintain records of STEM, if applicable, including the plan, any updates, and
the certification, and make them available to the Division upon request. In addition,
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for a rat st maintain records of any
required monitoring and make them available to the Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b.The date and duration of any period where the thief hatch, pressure relief device,
or other access point are found to be venting hydrocarbon emissions, except for
venting that is reasonably required for maintenance, gauging,or safety of personnel
and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment is
not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring such
equipment.
14. Minor sources in designated nonattainment or attainment/maintenance areas that are
otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance.This source shall meet the requirements to apply
RACT and reduce emissions by installing and operating an enclosed flare (Reference:
Regulation No. 3, Part B, III.D.2.a).
OPERATING & MAINTENANCE REQUIREMENTS
15. Flares shall be enclosed, have no visible emissions, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed flare, or by other
convenient means approved by the Division, determine whether the flare is operating
properly.
16. If a control device is used to comply with the emission limits of this permit, the following
conditions must be met:
a. Leakage of VOCs to the atmosphere must be minimized as follows:
(i) Thief hatch seals shall be inspected for integrity annually and replaced as
necessary. Thief hatch covers shall be weighted and properly seated.
(ii) Pressure relief valves (PRV) shall be inspected for proper operation
annually and replaced as necessary. PRVs shall be set to release at a
pressure that will ensure flashing, working and breathing losses are routed
to the control device under normal operating conditions.
(iii) Annual inspections of thief hatches and PRV shall be documented with an
indication of status, a description of any problems found, and their
corrective action.
17. Control devices shall be adequately designed, and operated and maintained according to
manufacturer specifications to achieve a control efficiency of at least 95%, and to handle
AIRS ID: 123/9586 Page 6 of 11
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reasonably for fl - -ti. • -mi VOCs tuations in emissions that
occur when the separator dumps into the tank are reasonably foreseeable.
18. The owner or operator shall monitor and document the proper operation of the control
device. Time intervals between monitoring shall not exceed 14 days. Indications of improper
operation for a flare include, but are not limited to, absence of pilot light, malfunction of
electronic ignition, and/or presence of smoke. A check box is suitable for recording proper
operation. Improper operation of a control device shall be further documented with a
description of the problem and its corrective action, the date range the control was
inoperable, and the produced water production through the battery during the downtime. If
the owner or operator cannot document the date that the control equipment became
inoperable then downtime shall be assumed to have started directly after the last
documented monitoring event. During control device downtime, emissions shall be
considered to be uncontrolled.
COMPLIANCE TESTING AND SAMPLING
19. No compliance requirements under this section.
ADDITIONAL REQUIREMENTS
20. All previous versions of this permit are cancelled upon issuance of this permit.
21. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Reference: Regulation No.3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than one hundred tons of VOC or NO.per year,
a change in annual actual emissions of one (1)ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5)tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
22. Federal regulatory program requirements (i.e. PSD, NANSR)shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
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condition. An n th to e ' ve the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until
a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted,then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide"final"authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued,the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
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D Color Depa e f bli and
it PollutionHealth ControlEnvironment Division
By:
Stephanie Chaousy, PE
Permit Engineer
Permit History_
Issuance Date Description
Issuance 1 This Issuance Issued to Noble Energy, Inc. Originally permitted
with categorical exemption, but Operator
requested a permit for a federally enforceable
permit limit less than 6 TPY.
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Notes to Permit Holder Dfolo Depa e f li Health and Environment
it Pollution Control Division
Notes to Permit Holderf an
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits maybe revised upon request of the
owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice(APEN)and complete application form
must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as
possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
httos://www.colorado.00v/oacific/cdohe/aocc-reas
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of
the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
MRS Rate emissions Emission
Point Pollutant CM# BIN (Ib/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 3500 Yes 175
009
n-Hexane 110543 C 11000 Yes 550
5) The emission levels contained in this permit are based on the following emission factors:
Point 009:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
lb/BBL Produced lb/BBL Produced
Water Throughput Water Throughput
VOC 0.262 0.0131 Source
110543 n-Hexane 0.022 0.0011 Source
71432 Benzene 0.007 0.0004 Source
Note: The controlled emissions factors for point 009 are based on the enclosed flare control
efficiency of 95%.
6) In accordance with C.R.S.25-7-114.1,each Air Pollutant Emission Notice(APEN)associated with this
permit is valid for a term of five years from the date it was received by the Division.A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit.For any questions regarding a specific expiration date call the Division at(303)-692-
3150.
7) This facility is classified as follows:
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Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC, CO, formaldehyde, n-hexane, benzene, total HAPS
NANSR Synthetic Minor Source of:
VOC, CO
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http //ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End SubpartA—SubpartKKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 SubpartA—SubpartZ
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart 7777—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9586 Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Noble Energy Inc.
Permit Number: 12WE2094
Source Location: Wells Ranch EcoNode—Sec 25
SWNW Sec25 T6N R63W, Weld County(non-attainment)
Equipment Description: Produced Water Storage
AIRS ID: 123-9586-009
Date: September 25, 2014
Review Engineer: Stephanie Chaousy
Control Engineer: Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no"to any of the above, when did you mail an
Information Request letter to the source? -
On what date was this application complete? April 23, 2014
Section 4—Source Description
AIRS Point Equipment Description
009 Six(6)above ground 500 bbl atmospheric produced water storage tanks.
Emissions from these tanks are controlled by an enclosed flare.
Are"flash" emissions anticipated from these tanks? X Yes No
Is this tank located at an E&P site? X Yes No
Is this tank located at a non-E&P, midstream or Yes X No
downstream site?
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria X Yes No
pollutant?
If"yes", for what pollutant? PM,() CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM:o CO Ozone
RACT per Regulation 3, Part B,Section III.D.2)
Page 1
Is this source claiming exempt status for this source
based on the fraction of oil in the stored water(less X Yes No
than 1% by volume crude oil on an average annual
basis)?
Are these produced water tanks located at a
commercial facility that accepts oil production Yes X No
wastewater for processing?
Are these produced water tanks subject to Colorado Oil
and Gas Conservation Commission (COGCC)805 Yes X No
Rule?
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
009 CDPHE Condensate Storage Tank Emission Factors; CDPHE Memo 09-02
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTE)
AIRS Point Process Consumption/Throughput/Production
009 600,000 BBL per year(500,000 x 1.2)wastewater
Basis for Actual Emissions Reported During this APEN Filino(Reported to-inventoro)
AIRS Point Process Consumption/Throughput/Production Data Year
009 500,000 BBL per year wastewater
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
009 500,000 BBL per year wastewater
Does this source use a control device? X Yes No
AIRS Point Process Control Device Description %Reduction
Granted
009 01 Enclosed Flare 95
Section 6—Emission Summary(tons per year)
Point NO, VOC CO Single HAP Total HAP
PTE: 009 — 78.6 — 6.6
(Hexane) 8.7
Uncontrolled point 009 - 65.5 - 5'5 7.3
source emission rate: (Hexane)
Controlled point 009 - 3.3 - 0.3 0.4
source emission rate: (Hexane)
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled an e,s
Pollutant CAS# BIN Emission Rate moats Controlled Emission
(lb/yr) reportable? Rate(lb/yr)
Benzene 71432 A 3500 Yes 175
n-Hexane 110543 C 11000 Yes 550
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on actual emissions without credit for reductions achieved by control devices
used by the operator.
Page 2
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes X No
standard?
Section 9—Source Classification
Is this a new previously un-permitted source? Yes X No
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V PSD X NA NSR X MACT
Is this a modification to an existing permit? X Yes No
If"yes"what kind of modification? X Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? Yes X No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards(NAAQS)?
If"yes", for which pollutants?Why?
AIRS Point Section 12—Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20%opacity. This standard is based on 24 consecutive opacity readings
taken at 15-second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July,
009 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Regulation 2—Odor
Section I.A- No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
009 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7)or more volumes of odor free air.
Regulation 3-APENs. Construction Permits, Operating Permits. PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
009 each individual emission point in a non-attainment area with uncontrolled actual emissions
of one tons per year or more of any individual criteria pollutant(pollutants are not summed)
for which the area is in non-attainment.
(Applicant is required to tile an APEN since emissions exceed 1 tons per year VOC)
Part B—Construction Permit Exemptions
Even though applicant meets the categorical exemption since the stored produced
009 water contains less than one percent by volume crude oil on an annual average
(Reg. 3, Part B, Section II.D.1.m), the operator requested a permit so that Noble has a
federally enforceable permit limit less than 6 TPY(NSPS 0000 requirements). _
Regulation 6- New Source Performance Standards
009 None
Page 3
Regulation 7-Volatile Organic'Ccmoounds
009 None
Regulation 8—Hazardous Air Pollutants
009 None
Section 13—Aerometric Information Retrieval System Coding Information
Emission Pollutant/ Fugitive Emission Factor Control
Point Process Process Description Factor CAS# (YIN) Source (%)
6.2381
lb/1000 VOC No CDPHE PS 95
gallons Memo 09-02
throughput
0.1667
01 Produced Water Storage lb/1000 Benzene No CDPHE PS 95
009 Tanks gallons Memo 09-02
throughput
0.5238
lb/1000 n-Hexane No CDPHE PS 95
gallons Memo 09-02
throughput
SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses
Section 14—Miscellaneous Application Notes
AIRS Point 009 Produced Water Storage Tanks
A permit-exempt/APEN-required letter was originally issued for this source. Even though applicant meets
the categorical exemption since the stored produced water contains less than one percent by volume
crude oil on an annual average(Reg. 3, Part B, Section II.D.1.m), the operator requested a permit so that
Noble has a federally enforceable permit limit less than 6 TPY (minimize the NSPS 0000 requirements).
State-Developed Emission factors in lb/1000 gal are:
Produced Water Tank Default
County Emission Factors(lb/1000 gal)
VOC Benzene n-Hexane
Adams, Arapahoe, Boulder, Broomfield, Denver, 6.2381 0.1667 0.5238
Douglas, Jefferson, Larimer and Weld
Page 4
STATE OF COLORADO
Coto
DRAFT HEALTH AND ENVIRONMENT `.
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
*1816 4
CONSTRUCTION PERMIT
PERMIT NO: 1 2WE231 7
Issuance 2
DATE ISSUED:
ISSUED TO: Noble Energy, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Wells Ranch Econode — Sec 25: TL-415817940 & TL-
415826210, located in the NWNW of Section 25, Township 6N, Range 63W, in Weld
County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
TL- Truck loadout of condensate. Emissions from the loadout are
415817940 070 not controlled.
TL- Truck loadout of condensate. Emissions from the loadout are
415826210 011 not controlled.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) after issuance of this permit, compliance with
the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self-certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit.
(Reference: Regulation No. 3, Part B, III.G.2).
2. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence"as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
AIRS ID: 123/9586 Page 1 of 8
Condensate Loadout TM Version 2012-1
olor Depa en li Health and Environment
it Pollution Control Division
deadline per R , - , N 3, art , Ill. 4.b Referen : Regulation No. 3, Part B,
II I.F.4.)
3. The operator shall retain the permit final authorization letter issued by the Division after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment Point Emission Type
ID VOC
TL- 010 9.4 Point
415817940
TL- 011 0.4 Point
415826210
See "Notes to Permit Holder for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each mohth and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
PROCESS LIMITATIONS AND RECORDS
5. This source shall be limited to the following maximum processing rates as listed below.
Annual records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
AIRS Process Parameter Annual Limit
Point _
010 Condensate Loading 1,825,000 BBL
011 Condensate Loading 85,000 BBL
AIRS ID: 123/9586 Page 2 of 8
olor Depa en Ii and Environment
it Pollution
Health Control Division
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility,for division review.
6. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TL-
415817940 010 Enclosed flare VOC and HAPS
TL- 011 Enclosed flare VOC and HAPS
415826210
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. This source is located in an ozone non-attainment or attainment-maintenance area and
is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
8. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
9. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations onsite at
the time of inspections to monitor compliance with Condition 9 (a) and (b) above.
The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
10. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
AIRS ID: 123/9586 Page 3 of 8
olo -� Depa en li Health and Environment
it Pollution Control Division
OPERATING & MAI E C R• 'U EM• T
11. Upon startup of these points,the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
12. Flare shall be enclosed, have no visible emissions, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed flare, or by other
convenient means approved by the Division, determine whether the flare is operating
properly.
13. The owner or operator of a loadout to control emissions shall:
a. Include devices to prevent the release of vapor from vapor recovery hoses not in
use.
b. Use operating procedures to ensure that hydrocarbon liquid cannot be
transferred unless the vapor collection equipment is in use.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief
hatch covers shall be weighted and properly seated.
d. Inspect pressure relief devices (PRD) annually for proper operation and replace
as necessary. PRDs shall be set to release at a pressure that will ensure
flashing, working and breathing losses are routed to the control device under
normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of
status, a description of any problems found, and their resolution.
COMPLIANCE TESTING AND SAMPLING
14. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
15. All previous versions of this permit are cancelled upon issuance of this permit.
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in
ozone nonattainment areas emitting less than 100 tons of V0C or NO per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN
AIRS ID: 123/9586 Page 4 of 8
olor Depa en li Health and Environment
it Pollution Control Division
For an on ter re le p uta :
If the - •ns i s % ) to r year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
in any permit condition. Any relaxation that increases the potential
virtue of a relaxation
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS:
18. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self-certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self-
Certify for Final Authorization section of this permit.
20. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information
and with representations made by the owner or operator or owner or operator's agents.
It is valid only for the equipment and operations or activity specifically identified on the
permit.
21. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
AIRS ID: 123/9586 Page 5 of 8
olor Depa en li Health and Environment
it Pollution Control Division
22. Each and eve on. .n th pe it is m vial part ereof and is not severable.
Any challeng- . . -ppe a on all co to a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephane Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 April 9, 2013 Issued to Noble Energy, Inc.
Issuance 2 This Issuance Modification in permit limits. Addition of enclosed
flares on each loadout. Sources at a synthetic
minor facility.
AIRS ID: 123/9586 Page 6 of 8
olor Depa en li Health and Environment
it Pollution Control Division
Notes to Permit Holder -. - o a
1) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions
Regulation. See:
htto://www.cdphe.state.co.us/reoulations/airreas/100102aocccommonprovisionsrea.odf.
3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS # (Ib/yr) reportable? Rate(Ib/yr)
-
n-Hexane 110543 5475 Yes 274
Benzene 71432 3650 Yes 183
010
Toluene 108883 5475 Yes 274
Xylenes 1330207 1825 Yes 91
n-Hexane 110543 255 Yes 13
Benzene 71432 170 No 9
011
Toluene 108883 255 Yes 13
Xylenes 1330207 85 No 4
4) The emission levels contained in this permit are based on the following emission factors:
Points 010 and 011:
Emission Factors- Emission Factors -
Uncontrolled Controlled
CAS Pollutant lb/bbl loaded Source Ib/bbl loaded Source
VOC 0.207 AP-42 0.0104 AP-42
71432 Benzene 0.002 Engineering 0.0001 Engineering
Calculation Calculation
108883 Toluene 0.003 Engineering 0.0002 Engineering
Calculation Calculation
1330207 Xylenes 0.001 Engineering 0.0001 Engineering
Calculation Calculation
110543 n-Hexane 0.003 Engineering 0.0002 Engineering
Calculation Calculation
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
AIRS ID: 123/9586 Page 7 of 8
olor Depa en li Health and Environment
it Pollution Control Division
L= 12.4: - ,
S= 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure)= 5.2 psia
M (vapor molecular weight)= 66 Ib/Ib-rnol
T(temperature of liquid loaded)= 520°R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated
using EPA Tanks
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with
this permit is valid for a term of five years from the date it was received by the Division.A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
6) This facility is classified as follows:
Applicable
Requirement Status
Operating Permit Synthetic Minor Source of:
VOC, CO, formaldehyde, n-hexane, benzene, total HAPS
NANSR Synthetic Minor Source of:
VOC, CO
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXX(
8) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at http://www.colorado.gov/oacific/cdphe/air-permit-selfcertification
AIRS ID: 123/9586 Page 8 of 8
Division Information
Engineer Stephanie Chaousy,PE
Control Engineer: Chris Laplante
Review Date: 09/25/2014
Application Dale: 04/23/2014
Facility Identifiers
Permit No. 12WE2317
County# 123 Weld
AIRs Facility# 9586
Point# 010
Section 01: Administrative Information
Company Name: Noble Energy,Inc
Source Name:TL-415817940
SWNW Sec 25 T6N R63W
Source Location:
SIC: 1311
Elevation(feet)4600
Portable Source? No
Portable Source Homebase
Mailing Address 1: Noble Energy,Inc
•
Address Address 2: 1625 Broadway,Suite 2200
City,State Zip: Denver,CO 80202
Name: Taryn Weiner
Person To Phone: 303-228-4362
Contact Fax: 303-228-4286
Email: tweinertldnobleenergyinc.com
•
AP-42:Chapter 5.2
Equation 1
L=12.46'5 P1MT
L=loading losses in lb per 1000 gallons loaded
S=Saturation Factor
P=true vapor pressure of liquid loaded Ipsial
M=molecular weigh(of vapors[lb/lb-mole]
T=temperature of bulk liquid loaded[deg.R]
1 degree Fahrenheit=460.67 degree Rankine
S 0.6 Submerged loading:dedicated normal service
P 5.2 psia
M 66 lb/lb-mole
T 520 deg.R
4.93 lb/10"3 gal
2.07E-01 lb/bbl
Annual requested Throughput 76650000 gal/yr
Annual requested VOC emissions 378203 lb/yr
189.10 tpy uncontrolled
946 tpy controlled
Regulatory Considerations
This facility is not condisdered a terminal(in Reg.7)because average daily throughput will be
below 20,000 gallons at 3,956 gallons per day.
This facility is not considered a bulk plant(in Reg.7)because it does not distribute gasoline.
NCRPs Uncontrolled Contolled E.F. E.F. Operator Operator Operator
Component col% ID/yr Ibyr Iblbbl lb/1000 gal lb* lb/bbl lb/1000 gal
Benzene 0.90% 3404 170.19 0.0019 00444 3650 0.0020 0.0476
Toluene 1.30% 4917 245.83 0.0027 0.0641 5475 0.0030 0.0714
Ethylbenzene 0.1D% 378 18.91 0.0002 0.0049 0 00000 0.0000
Xylenes 0.50% 1891 94.55 0.0010 0.0247 1825 00010 0.0238
n-hexane 1.60% 6051 302.56 0.0033 0.0789 5475 00030 0.0714
'Will use operator's emissions. 1 believe the discrepancy is due to rounding issues.
'Assumed HAP concentrations from Table 3-2 of DOC#EPA-453/R-94-002a
Division Information
Engineer: Stephanie Chaousy,PE
Control Engineer Chris Laplante
Review Date: 09/25/2014
Application Date: 04/23/2014
Facility Identifiers
Permit No. 12WE2317
County# 123 Weld
AIRS Facility# 9586
Point# 011
Section 01: Administrative Information
Company Name: Noble Energy,Inc
Source Name: TL-415817940
SWNW Sec 25 T6N R63W
Source Location:
SIC: 1311
Elevation(feet)4600
Portable Source?No
Portable Source Homebase
Mailing Address 1: Noble Energy,Inc
Address Address 2: 1625 Broadway,Suite 2200
City,Slate Zip: Denver,CO 80202
Name: Taryn Weiner
Person To Phone: 303-228-4362
Contact Fax: 303-228-4286
Email: tweinertnobleenerovinc.com
AP-42:Chapter 5.2
Equation 1
L=12.46'S'P'M/T
L=loading losses in lb per 1000 gallons loaded
S=Saturation Factor
P=We vapor pressure of liquid loaded 1psial
M=molecular weigh(of vapors[Ibab-mole]
T=temperature of bulk liquid loaded!deg.R]
1 degree Fahrenheit=460.67 degree Rankine
5 0.6 Submerged loading:dedicated normal service
P 5.2 psia
M 66 lb/lb-mole
T 520 deg.R
L 4.93 lb/10^3 gal
2.07E-01 lb/bbl
Annual requested Throughput 3570000 gal/yr
Annual requested VOC emissions 17615 lb/yr
8.81 tpy uncontrolled
0.44 tpy controlled
Regulatory Considerations
This facility is not condisdered a terminal(in Reg.7)because average daily throughput will be
below 20,000 gallons at 3.956 gallons per day.
This facility is not considered a bulk plant(in Reg.7)because it does not distribute gasoline.
NCRPs Uncontrolled Cootdled E.F. E.F. Operator Operator Operator
Component wt% lb/yr INyr Ibrbbl lb/1W0 gal lb/yr lb/bbl lb/1000 gal
Benzene 0.90% 159 7.93 0.0019 0.0444 170 0.0020 0.0476
Toluene 1.30% 229 11.45 0.0027 0.0641 255 0.0030 0.0714
Ethylbenzene 0.10% 18 0.88 0.0002 0.0049 0 0.0000 0.0000
Xylenes 0.50% 88 4.40 0.0010 0.0247 85 0.0010 0.0238
n-hexane 1.60% 282 14.09 0.0033 0.0789 255 0.0030 0.0714
'Will use operatoes emissions. I believe the discrepancy is due to rounding issues.
'Assumed HAP concentrations from Table 3-2 of DOC#EPA-453/R-94-002a
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Noble Energy, Inc
Permit Number 13WE1098
Source Location: Battery#415817940
SWNW Sec25 T6N R63W, Weld County (non-attainment)
Point 007: 16-500 bbl condensate tanks
Equipment Description:
Point 008: 2-500 bbl condensate tanks
AIRS ID: 123-9586
Date: September 25, 2014
Review Engineer Stephanie Chaousy
Control Engineer: Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP2 Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? Yes X No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? Yes X No
Did the applicant provide ample information to determine emission rates? Yes X No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete? April 23, 2014
Section 4—Source Description
AIRS Point Equipment Description
007 Sixteen (16)above ground 500 bbl atmospheric condensate storage tanks.
Emissions from these tanks are closed by an enclosed flare.
008 Two (2)above ground 500 bbl atmospheric condensate storage tanks. Emissions
from these tanks are closed by an enclosed flare.
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria X Yes No
pollutant?
If"yes", for what pollutant? PM,() CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
Is this source located in the 8-hour ozone non-
attainment region?(Note: If"yes" the provisions of X Yes No
Regulation 7, Sections XII and XVII.C may apply)
Page 1
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
007,008 Source provided site-specific emission factors using gas sample and WinSim.
Previously approved with Issuance 1 (TRIM dated 5/4/12).
Did the applicant provide actual process data for the emission inventory? Yes X No
Basis for Potential to Emit(PTEI
AIRS Point Process Consumption/Throughput/Production
007 1825000 BBL per year
008 85000 BBL per year
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
007 1825000 BBL per year
008 85000 BBL per year
Does this source use a control device? X Yes No
AIRS Point Process Control Device Description % Reduction
Granted
007,008 01 Flare 95.0
Section 6—Emission Summary(tons per year)
Point NO, VOC CO Single HAP Total HAP
007 3.3 292 2.7 8.2 (hexane) 9.2
PTE:
008 0.2 13.6 0.1 0.4 (hexane) 0.4
007 3.3 292 2.7 8.2 (hexane) 9.2
Uncontrolled point emission rate:
008 0.2 13.6 0.1 0.4 (hexane) 0.4
007 3.3 14.6 2.7 0.4 (hexane) 0.5
Controlled point emission rate:
008 0.2 0.7 0.1 0.02 (hexane) 0.02
Total APEN Reported emissions: 3.3 15.3 2.7 0.42(hexane) 0.52
Section 7—Non-Criteria/Hazardous Air Pollutants
Pollutant CAS# BIN Point Uncontrolled Emission an Me emissions Controlled Emission Rate(Ibtyr)
Rate(lbtyr)
007 2008 YES 100
Benzene 71432 A
008 94 No 5
007 16425 YES 821
n-Hexane 110543 C
008 765 YES 38
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes X No
standard?
Page 2
Section 9—Source Classification
Is this a new previously un-permitted source? Yes X No
True Synthetic
What is this facility classification? X Major
Minor Minor
Classification relates to what programs? X Title V PSD X NA NSR MACT
Is this a modification to an existing permit? X Yes No
If"yes"what kind of modification? X Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? X Yes No
If"yes",for which pollutants?Why?
For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards(NAAQS)?
AIRS Point Section 12—Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15-second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60,Appendix A(July,
007,008 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Regulation 2—Odor
Section I.A- No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
007,008 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3-APENs, Construction Permits. Operating Permits, PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
007,008 each individual emission point in a non-attainment area with uncontrolled actual emissions
of one ton per year or more of any individual criteria pollutant(pollutants are not summed)
for which the area is in non-attainment.
(Applicant is required to file an APEN since emissions exceed 1 ton per year VOC)
Part B—Construction Permit Exemptions
007,008 Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold(Reg.3, Part B, Section 11.D.3.a)
Regulation 6- New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
007,008 Is this source greater than 19,800 gallons(471 bbl)? Yes
Is this source subject to NSPS Kb? No
This is at an E&P site and is below 10,000 barrels.
Page 3
Regulation 7-Volatile Organic-Compounds
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is subject to the emission control requirements for condensate tanks
007,008 since it is located in a non-attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions am
greater than 20 tpy of VOC.)
Regulation 8-Hazardous Air Pollutants
MACT EEEE: Organic Liquids Distribution
007,008 This source is not subject to MACT EEEE because it is located at a"production field
facility"as defined in 40 CFR 63.761 (located upstream of the natural gas processing
plant).
007,008 MACT HH
This source is not subject to MACT HH because it is not located at a major source of HAP.
Section 13—Aerometric Information Retrieval S)stem Coding Information
Process Pollutant/ Fugitive Emission Fador Control
Point Process Description Emission Factor CAS# (Y/N) Source (%)
7.619 lb/1000 gal VOC No Chemical Analysis 95
throughput and Winsim
E&P 0.086 Ib/1000 gal NO No Chemical Analysis WA
01 Condensate throughput and Winsim
007, Storage 0.02619 lb/1000 gal Benzene/ Chemical Analysis
008 Tanks throughput 71432 No and Winsim 95
0.2143 Ib/1000 gal n-Hexane/ No Chemical Analysis 95
throughput 110543 and Winsim
SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses
Section 14—Miscellaneous Application Notes
AIRS Point 007,008 Condensate Storage Tanks
Site-specific emissions were approved in Issuance 2 and were re-used with this modification. Emissions
for Point 007 increased while they decreased for Point 008. Final issuance of the permit was issued
1/14/14, and this modification does not warrant re self-certification. I will issue this permit as an FA.
VOC=0.32 Ib/bbl *1000/42=7.6190 lb/1000 gal
Benzene= 0.0011 Ib/bbl * 1000/42= 0.02619 Ib/1000 gal
n-hexane= 0.009 Ib/bbl• 1000/42= 0.2143 Ib/1000 gal
Page 4
STATE OF COLORADO
pF Cow
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ��'_
AIR POLLUTION CONTROL DIVISION e
TELEPHONE:(303)692-3150 * .
. N.
.1876"
CONSTRUCTION PERMIT
PERMIT NO: 1 3WE1 098
Issuance 2
DATE ISSUED:
ISSUED TO: Noble Energy, Inc
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Batteries #415826210 & #415817940, Wells Ranch
Econode — Sec 25, located in the SWNW of Section 25, Township 6N, Range 63W, in
Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
Sixteen (16) 500 BBL fixed roof storage tanks used to store
TANK 1 007 condensate. Emissions from these tanks are controlled by an
enclosed flare.
Two (2) 500 BBL fixed roof storage tanks used to store
TANK 2 008 condensate. Emissions from these tanks are controlled by an
enclosed flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) after issuance of this permit, compliance with
the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self-certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit.
(Reference: Regulation No. 3, Part B, III.G.2).
2. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; iii does not complete construction within a reasonable
9 O P
time of the estimated completion date. The Division may grant extensions of the
AIRS ID: 123/9586 Page 1 of 8
Condensate Tank SM/M Version 2012-1
Depa en li Health and Environment
it Pollution Control Division
deadline perDolor
, II efere • Regulation No. 3, Part B,
III.F.4.)
3. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the sett-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
4. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section ll.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point NO, VOC CO Emission Type
Tank 1 007 3.3 14.6 2.7 Point
Tank 2 008 - 0.7 — Point
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
6. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility Equipment ID AIRS Point Control Device Pollutants Controlled
Tank 1 007 Enclosed Flare VOC, HAPs
Tank 2 008 Enclosed Flare VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
AIRS ID: 123/9586 Page 2 of 8
olor Depa en Ii andEnvironment
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Process/Con-
Facility Equipment ID AIRS Point Process Parameter Annual Limit
Tank 1 007 Condensate throughput 1,825,000 BBUyr
Tank 2 008 Condensate throughput 85,000 BBUyr
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. &4.)
10. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General
Provisions (State only enforceable). If a combustion device is used to control emissions
of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no
visible emissions, and be designed so that an observer can, by means of visual
observation from the outside of the enclosed combustion device, or by other means
approved by the Division, determine whether it is operating properly. The operator shall
comply with all applicable requirements of Section XII.
12. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). If a flare or other combustion device is used to
control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed, have no visible emissions during normal operations, and be designed so that
an observer can, by means of visual observation from the outside of the enclosed flare
or combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. The operator shall comply with all applicable
requirements of Section XVII.
14. The condensate storage tanks covered by this permit are subject to Regulation 7,
Section XVII emission control requirements. These requirements include, but are not
limited to:
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas
exploration and production operations, natural gas compressor stations,
AIRS ID: 123/9586 Page 3 of 8
olo Depa en li Health and Environment
it Pollution Control Division
naturD na proc g plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate
storage tanks with uncontrolled actual emissions of volatile organic
compounds equal to or greater than 20 tons per year based on a rolling
twelve-month total shall operate air pollution control equipment that has an
average control efficiency of at least 95%for VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is
required to control volatile organic compound emissions pursuant to this
section XVII.C. shall visually inspect or monitor the Air Pollution Control
Equipment to ensure that it is operating at least as often as condensate is
loaded out from the tank, unless a more frequent inspection or monitoring
schedule is followed. In addition, if a flare or other combustion device is used,
the owner or operator shall visually inspect the device for visible emissions at
least as often as condensate is loaded out from the tank.
XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank
shall maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled
pursuant to this section XVII.C., the date, time and duration of any
period where the air pollution control equipment is not operating. The
duration of a period of non-operation shall be from the time that the air
pollution control equipment was last observed to be operating until the
time the equipment recommences operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the
date and time of any instances where visible emissions are observed
from the device.
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with Condition 12, using EPA
Method 22 to measure opacity from the flare. The observation period shall be a
minimum of fifteen consecutive minutes.
ADDITIONAL REQUIREMENTS
17. All previous versions of this permit are cancelled upon issuance of this permit
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
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olor Depa en li Health and Environment
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For a
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5)tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,,) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO, per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section 'LB upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self-certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self-
Certify for Final Authorization section of this permit.
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22. This permit iD an pleteness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information
and with representations made by the owner or operator or owner or operator's agents.
It is valid only for the equipment and operations or activity specifically identified on the
permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 June 26, 2013 Issued to Noble Energy, Inc.
Issuance 2 This Issuance Modification to permit limits. Sources at synthetic
minor facility.
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Notes to Permit Holder - o a
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See:
http://www.cdphe.state.co.us/reoulatons/airregs/100102aocccommonprovisionsrea.pdf.
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled Are the Controlled
AIRS Emission Rate emissions Emission
Point Pollutant CAS# BIN (lb/yr) reportable? Rate(lb/yr)
Benzene 71432 A 2008 Yes 100
007
Hexane 110543 C 16425 Yes 821
Benzene 71432 A 94 No 5
008
Hexane 110543 C 765 Yes 38
5) The emission levels contained in this permit are based on the following emission factors:
Points 007 and 008:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
lb/BBL Condensate lb/BBL Condensate
Throughput Throughput
VOC 0.32 0.016 Source
NOx 0.0036 N/A Source
CO 0.0030 N/A Source
110543 n-Hexane 0.009 0.00045 Source
71432 Benzene 0.0011 0.000055 Source
Note: The controlled emissions factors for points 007 and 008 are based on the flare control
efficiency of 95%.
AIRS ID: 123/9586 Page 7 of 8
olo Depa en Ii Health and Environment
it Pollution Control Division
6) In accordance with -7 1, it missi tice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date calf the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable Requirement Status
Operating Permit Synthetic Minor Source of:
VOC, CO, formaldehyde, n-hexane, benzene, total HAPS
NANSR Synthetic Minor Source of:
VOC, CO
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below.
http://ecfnizpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart 7777—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXX(
9) A self certification form and guidance on how to self-certify compliance as required by this permit
may be obtained online at: htto://www.colorado.00v/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9586 Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Division Information
Engineer: Stephanie Chaousy, PE Attainment Status
Control Engineer: Chris Laplante' PM10 Attainment
Review Date: 11/10/2014 PM2.5 Attainment
Application Date: 04/23/2014 SOx Attainment
NOx Nonattainmen
VOC Nonattainmen
Facility Information CO Attainment
Permit No. 14WE0968
County# 123 Weld Potentially Located within EAC-determine attainment status of NO:
AIRs Facility# 9586
Point# 012
Facility Equipment ID Flare
Company Name: Noble Energy,Inc.
Source Name: Wells Ranch EcoNode 25
NWNW Section 25,T6N,R63W
Source Location:
SIC: 1311
Elevation(feet)4600
APEN
New Permit Modification
X (CPI) (Issuance#) Required/Permit
Exemnt
Transfer of APEN
Ownership Exempt/Permit
Fxpmnt
Notes
Equipment Description
This source vents natural gas from: a well head separator
Emissions from this source are: routed to an open-flame flare
Natural gas venting from a well head separator.Emissions from this source are routed to an open-
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3)
Ex=Q"MW"Xx/C
Ex=emissions of pollutant x
O=Volumetric flow rate/volume of gas processed
MW=Molecular weight of gas=SG of gas'MW of air
Xx=mass fraction of x in gas
C=molar volume of ideal gas(379 scf/Ib-mot)at 60F and 1 atm
Throughput(0) 91 MMscflyr 10388.1 scf/hr 7.73 MMscf/mo
MW 22.450 Ib/Ib-mot I 0.002 MMscf/d I
mole T. MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy
Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00
CO2 2.707 44.01 1.191 0.053 CO2 32.7 , 286050 143.02
N2 0.525 28.013 0.147 0.007 N2 4.0 35312 17.66
methane 72.093 16.041 11.564 0.515 methane 317.0 2776686 1388.34
ethane 13.969 30.063 4.200 0.187 ethane 115.1 1008323 504.16
propane 7.596 44.092 3.3492 0.149 propane 91.8 804168 402.08
isobutane 0.72 58.118 0.4184 0.019 isobutane 11.5 100472 50.24
n-butane 1.88/ 56.118 1.095/ 0.049 n-butane 30.1 253321 131.56
isopentane 0.222 72.114 0.1601 0.007 isopentane 4.4 38439 19.22
n-pentane 0.222 /2.114 0.1601 0.00/ n-pentane 4.4 3843' 19.22
cyclopentane 0 70.13 0.0000 0.000 cyctopentane 0.0 0 0.00
n-Hexane 0.0000 86.18 0.0000 0.000 n-Hexane 0.0 0 0.00
cyclohexane 0.0000 84.16 0.0000 0.000 cyclohexane 0.0 0 0.00
Otherhexanes 0 86.18 0.0000 0.000 Otherhexanes 0.0 0 0.00
heptanes 0 100.21 0.0000 0.000 heptanes 0.0 0 0.00
methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00
224-TMP 0 114.23 0.0000 0.000 224-TMP 0.0 0 0.00
Benzene 0 78.12 0.0000 0.000 Benzene 0.0 0 0.00
Toluene 0 92.15 0.0000 0.000 Toluene 0.0 0 0.00
Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00
Xylenes 0 106.17 0.0000 0.000 Xylenes 0.0 0 0.00
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+Heavies I 0.0591 276.4271 0.1631 1 0.007 IC8+Heavies I 4.5 I 39159 19.58
VOC mass fraction: 0.2382 Total VOC Emissions(Uncontrolled) 642.0
22.450 annual limit assuming 95%control 32.1
Notes monthly limit assuming 95%control(lb/mo.) 5452.6
Mole%,MW.and mass fractions from WR 25 Check#2 gas analysis.
Emissions are based on 8760 hours of operation per year. Operator calculated 684.0 TPY uncontrolled. This is
I calculated the average MW of C8+based on the average MW on the analysis for the gas.higher and probably due to rounding issues. I will permit
using operator numbers and a controlled VOC emissions
Flaring Information of 342 Tpy
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer TBD
Model TBD
Serial Number TBD
Gas Heating Value 1281 Btu/scf
Throughput 116571 MMBtu/yr
Combustion emission factor source: AP-42:Chapter 13.5
0.068 lb NOX/MMBtu 0.37 lb CO/MMBtu
3.96 tpy NOX 21.57 tpy CO
Emissions Summary
3.96 tpy NOX
Uncontrolled/PTE 21.57 tpy CO
641.999 tpy VOC
Controlled 32.100 tpy VOC
Because the gas analysis did not spectate the HAPS,Noble conservative'calculated HAPS using wt%taken from the facility
Uncontrolfe Scenario A Controlled
Wt% d Total Reportable? Total(lb/yr)
Benzene 0.20% 10762 Yes 538
Toluene 0.20% 10762 Yes 538
Ethylbenzene 0.10% 5381 Yes 269
Xylenes 0.10% 5381 Yes 269
n-hexane 0.60% 32378 Yes 1619
224-TMP 0.10% 5381 Yes 269
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.'
AQCC Regulation 2
Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven(7)or more volumes of odor free air."
AQCC Regulation 3
An APEN is required for this source because uncontrolled VOC emissions
Part A: exceed one ton per year in a nonattainment area for ozone.
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed two tons per year in a nonattainment area for ozone.
Part B: This source is subject to Section III.D.2(Minor Source RACT)because it is
located in a nonattainment area.RACT for this source has been determined to
be the use of a flare to control emissions.
Is public comment Public Comment Required
required?
STATE OF COLORADO
�F Co,
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ��'-
AIR POLLUTION CONTROL DIVISION '
TELEPHONE:(303)692-3150 . .J
s 1876♦
CONSTRUCTION PERMIT
PERMIT NO: 14W E0968
Issuance 1
DATE ISSUED:
ISSUED TO: Noble Energy, Inc. .
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Wells Ranch EcoNode Sec-25 located in the SWNW of
Section 25, Township 6 North, Range 63 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Flare 012 Separator controlled by a flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN
THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control Commission
(AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the
permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i)does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
AIRS ID: 123/9586 Page 1 of 8
Wellhead Version 2012-1
I
Col D men f PubD
lic PollutionHealthand ControlEnvironment Division
application associated with this permit; (ii)discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information for all permitted equipment except fugitive emissions from
equipment leaks shall be provided to the Division within fifteen (15) days after issuance of
permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification,with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type
Flare 012 4.0 32.2 21.6 Point
See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9586 Page 2 of 8
Col.j • D= men .f Public Health and Environment
Air Pollution Control Division
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Flare 012 Separator controlled by a flare stack VOC, HAPS
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available to
the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
Flare 012 Natural gas flaring 91 MMSCF/yr
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
11. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
12. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
13. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING& MAINTENANCE REQUIREMENTS
14. Upon startup of these points,the applicant shall follow the operating and maintenance(O&M)
plan and record keeping format approved by the Division, in order to demonstrate compliance
on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are
subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B,
Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
AIRS ID: 123/9586 Page 3 of 8
D Col D men f Public Health and Environment
Air Pollution Control Division
15. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene,toluene, ethylbenzene,xylenes, n-
hexane, and 2,2,4-trimethylpentane content(weight fraction)of this emission stream used in
the permit application. Results of testing shall be used to determine site-specific emission
factors using Division approved methods. Results of site-specific sampling and analysis
shall be submitted to the Division as part of the self-certification and used to demonstrate
compliance with the emissions factors chosen for this emissions point.
16. The owner or operator shall demonstrate compliance with opacity standards using EPA
Method 22 to measure opacity from the flare. (Reference: Regulation No. 1, Section I I.A.5).
Periodic Testing Requirements
17. On an annual basis, the operator shall complete a site specific extended gas analysis of the
natural gas produced at this site that is routed to the flare in order to verify the VOC content
(weight fraction) of this emission stream used in the permit application. Results of testing
shall be used to determine site-specific emission factors using Division approved methods.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5)tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed,or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements(i.e. PSD, NANSR)shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until
a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9586 Page 4 of 8
Col D men f Public PollutionHealthand Control DivisionEnvironment
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide"final"authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the applicant and is conditioned upon conduct of the activity, or construction, installation
and operation of the source, in accordance with this information and with representations
made by the applicant or applicant's agents. It is valid only for the equipment and operations
or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant, or the Division revokes a permit,the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
AIRS ID: 123/9586 Page 5 of 8
Col D men f Public Health and Environment
Air Pollution Control Division
Issuance 1 This Issuance Issued to Noble Energy, Inc. Newly permitted
separator flare at a synthetic minor facility.
AIRS ID: 123/9586 Page 6 of 8
Col.�j . D* men .f Public Health and Environment
II
Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3,
Part A, Section VI.B.)
i
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits maybe revised upon request of the
permittee providing there is no exceedance of any specific emission control regulation or any ambient air
quality standard. A revised air pollution emission notice(APEN)and application form must be submitted
with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as
possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
https://www.colorado.00v/pacific/cdphe/aocc-reos
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of
the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 10762 Yes 538
Toluene 108883 C 10762 Yes 538
012 Ethyl benzene 100414 C 5381 Yes 269
Xylenes 1130207 C 5381 Yes 269
n-Hexane 110543 C 32378 Yes 1619
5) The emission levels contained in this permit are based on the following emission factors:
Point 012:
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas(/o) Uncontrolled Controlled
NOx 0.068 0.068 AP-42
Ib/MMBtu Ib/MMBtu
CO 0.37 AP-42
0.37 lb/MMBtu lb/MMBtu
VOC 23.83 14109.8745 705.4937 Engineering
Ib/mmscf Ib/mmscf Calculation
71432 Benzene 0.20 118.2637 5.9132 Engineering
b/mmscf Ib/mmscf Calculation
108883 Toluene 0.20 118.2637 5.9132 Engineering
lb/mmscf lb/mmscf Calculation
100414 Ethylbenzene 0.10 59.1319 2.9566 Engineering
Ib/mmscf Ib/mmscf Calculation
AIRS ID: 123/9586 Page 7 of 8
PkFmTlic
Air PollutionHealthand ControlEnvironment Division
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors
Gas(%) Uncontrolled Controlled Source
1330207 Xylenes 0.10 59.1319 2.9566 Engineering
lb/mmscf lb/mmscf Calculation
110543 n-hexane 0.60 355.8022 17.7901 Engineering
Ib/mmscf lb/mmscf Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the December
4, 2013 analysis of a gas sample collected from the WR 25 Check#2 well.The controlled
VOC and HAP emissions factors for point 012 are based on the flare control efficiency of 95%.
6) In accordance with C.R.S.25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with this
permit is valid for a term of five years from the date it was received by the Division.A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at(303)-692-
3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC, CO, formaldehyde, n-hexane, benzene, total HAPS
NANSR Synthetic Minor Source of:
VOC, CO
8) Full text of the Title 40,Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart 7777—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: htto://www.colorado.00v/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9586 Page 8 of 8
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Mr Pollutant Emission Notice(APEN)—and—Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Current Status(Check all that apply) Reason for APEN Submittal(Check all that apply) Z.LC7;
AIRS ID#l: 123-9586-007 0 APEN update only° a
O New or previously unreported battery 0 Modification to existing sources [ �._ 3t32
S
0 Previously grandfathered battery' 0 Registration for coverage under general permit no.GP0Ti and
® Synthetic minor facility cancellation request for individual permits: "C
® Located in the 8-hr Ozone Control Areas ❑ Application for or Modification of an individual permit
❑ Registered under general permit no.GP01 0 Administrative permit amendment'
O Permitted under individual permit: 13WE1098 0 Other:
For individual permit applications,check if you wants: 0 A copy of the preliminary analysis conducted by the Division
❑To review a draft of the permit prior to issuance
Company Name': Noble Energy,Inc OGCC Operator#: 100322
Mailing Address10: 1625 Broadway
tweiner@nob lee nergyinc
City: Denver State: CO Zip: 80202 E-mail: .com
Contact Name: Taryn Weiner Phone: (303)228-4362 Fax: (303)228-4280
Tank Battery Name: BATTERY#415817940 WELLS RANCH ECONODE-SECTION 25 Number of tanks: 16
Location"(QQ Sec.Twp.Range.): SWNW SEC25 T6N R63W County: Weld Total tank capacity[bbl]: 8,000
Calendar year for which"Actual"data applies13: 2012 Year(s)tank(s)were placed in service: 2012
Control Descriptions: Enclosed Flare Control Efficiency16: 95%
Condensate Throughput'[bbl/year] Requested's: 1,825,000 Maximum for PTE calculation 19: 1,825,000
I Actual2s: While Controls Operational21
Other equipment at facility22:
Comments:
Estimated emissions at throughputs listed above. Use NM for requested throughput/emission values unless requesting an individual permit
0 Check if the Division is to calculate emissions. ®Check if site-specific emission factors provided to calculate emissions23.
Emission Factor Battery Requested Emissions" Actual Emissions20
Pollutant" [lb/bbl] PTE25 Uncontrolled26 Controlled" Uncontrolled26 Controlled"
VOC[tons/year] 0.32 292.0 292.0 14.6
NOx[tons/year] 0.0036 3.3 3.3 3.3
CO[tons/year] 0.003 2.7 2.7 2.7
Benzene[lbs/year] 0.0011 2,007.5 2,007.5 100.4
n-Hexane[lbs/year] 0.009 16,425.0 16,425.0 821.3
Wells serviced by this tank or tank battery's
API#: 05-123-34233 Name: WELLS RANCH USX AA25-65HN 0 Newly Reported Well
API#: 05-123-34423 Name: WELLS RANCH USX AA25-67HN ❑Newly Reported Well
API It: 05-123-34237 Name: WELLS RANCH USX AA25-63-0IHN 0 Newly Reported Well
Apl#: 05-123-34234 Name: WELLS RANCH USX AA25-64-0IHN 0 Newly Reported Well
API#: 05-123-34232 Name WELLS RANCH USX AA25-66-0 I FIN 0 Newly Reported Well
API#: 05-123-34236 Name: WELLS RANCH USX AA25-65-0 I HN 0 Newly Reported Well
API#: 05-123-34424 Name: WELLS RANCH USX AA25-68-01 HN 0 Newly Reported Well
pH#: 05-123-34421 Name: WELLS RANCH USX AA25-67-01HN 0 Newly Reported Well
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true,accurate,and complete to the best of
my knowledge and belief. If this is a registration for coverage under general permit GP I,I further certify that this source is and will be operated
in fill); with each condition of general permit GP 1.
ti (A 2-0—;:-.., April 23,2014
Signature SLegally Authorized Person(not a vendor or consultant) Date
Taryn Weiner Environmental Engineer
Type or Print Name of Person Signing Above Official Title
Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call:
filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B I 309179
(303)692-3150
$250 General Permit fee for each new GP 4300 Cherry Creek Drive South
registration to: Denver,CO 80246-1530
FORM APCD-205 Page 1 of 4415817940 WELLS RANCH ECONODE-SECTION 25-Modification.doc
Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit
Oli AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Wells serviced by this tank or tank battery
API#: 05-123-37567 Name: WELLS RANCH AA26-62-1HN
0 Newly Reported Well
API#: 05-123-37563 Name WELLS RANCH AA26-63-IHN 0 Newly Reported Well
API#: 05-123-37566 Name: WELLS RANCH AA26-63HN _
0 Newly Reported Well
API#: 05-123-37565 Name: WELLS RANCH AA26-64-1HN
0 Newly Reported Well
API#: 05-123-37569 Name: WELLS RANCH AA26-65-1HN 0 Newly Reported Well
API#: 05-123-37568 Name: - WELLS RANCH AA26-65HN
0 Newly Reported Well
API#: 05-123-37564 Name: WELLS RANCH AA26-66-1HN
®Newly Reported Well
API#: 05-123-34527 Name: WELLS RANCH AA26-67-1HN ®Newly Reported Well
API#: 05-123-34524 Name WELLS RANCH AA26-68-1 HN
0 Newly Reported Well
API#: 05-123-34528 Name: WELLS RANCH AA26-69HN
0 Newly Reported Well
API#: Name: O Newly Reported Well
API#: Name: O Newly Reported Well
API#: Name: O Newly Reported Well
O Newly Reported Well
Page 2 of 4 415817940 WELLS RANCH ECONODE-SECTION 25-Modification
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Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit
- OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Current Status(Check all that apply) Reason for APEN Submittal(Check all that apply)
AIRS ID#': +-237-9568=6,08. 123145%/O0 B 0 APEN update only°
❑ New or previously unreported ba ery 0 Modification to existing sources Lam"
❑ Previously grandfathered battery2 0 Registration for coverage under general permit no.GPOI. .
® Synthetic minor facility cancellation request for individual permits: �' '.-
® Located in the 8-hr Ozone Control Areas ElApplication for or Modification of an individual t¢`%II
❑ Registered under general permit no.GP01 0 Administrative permit amendments /
® Permitted under individual permit: 13WE1098 0 Other:
For individual permit applications,check if you wants: 0 A copy of the preliminary analysis conducted by the Division
❑To review a draft of the permit prior to issuance
Company Name9: Noble Energy,Inc OGCC Operator#: 100322
Mailing Address10: 1625 Broadway
tweiner@nobleenergyinc
City: Denver State: CO Zip: 80202 E-mail: .com
Contact Name: Taryn Weiner Phone: (303)2284362 Fax: (303)2284280
Tank Battery Name I: BATTERY#415826210 WELLS RANCH ECONODE-SECTION 25 Number of tanks: 2
Locationt2(QQ Sec.Twp.Range.): SWNW SEC25 T6N R63W County: Weld Total tank capacity[bbl]: 1,000
Calendar year for which"Actual"data applies13: 2012 Year(s)tank(s)were placed in service": 2012
Control Descriptions: Enclosed Flare Control Efficiency's: 95%
Condensate Throughput's[bbl/year] Requested": 85,000 Maximum for PTE calculation19: 85,000
Actual�0: While Controls Operational2'
Other equipment at facility22:
Comments:
Estimated emissions at throughputs listed above. Use NM for requested throughput/emission values unless requesting an individual permit
0 Check if the Division is to calculate emissions. 0 Check if site-specific emission factors provided to calculate emissions23.
Emission Factor Battery Requested Emissions" Actual Emissions20
Pollutant24 [lb/bbl] PTE25 Uncontrolled26 Controlled27 Uncontrolled26 Controlled"
VOC[tons/year] 0.32 13.6 13.6 0.7
NOx[tons/year] 0.0036 0.2 0.2 0.2
CO[tons/year] 0.003 0.1 0.1 0.1
Benzene[lbs/year] 0.0011 93.5 93.5 4.7
n-Hexane[lbs/year] 0.009 765.0 765.0 38.3
Wells serviced by this tank or tank battery2s
API#: 05-123-34566 Name: WELLS RANCH USX AA25-69HN 0 Newly Reported Well
API#: Name: 0 Newly Reported Well
API#: Name: 0 Newly Reported Well
API#: Name: 0 Newly Reported Well
API#: Name 0 Newly Reported Well
API#: Name: 0 Newly Reported Well
API#: Name: 0 Newly Reported Well
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true,accurate,and complete to the best of
my knowledge and belief. If this is a registration for coverage under general permit GPI,I further certify that this source is and will be operated
in full compliance with each condition of general permit GPI.
Ct*1y3 April 23,2014
Signature of gai wly Authorized Person(not a vendor or consultant) Date
Taryn Weiner Environmental Engineer
Type or Print Name of Person Signing Above Official Title
Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call:
filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-BI (303)692-3150
$250 General Permit fee for each new GP 4300 Cherry Creek Drive South 309180
agistration to: Denver,CO 80246-1530
FORM APCD-205 Page 1 of 2415826210 WELLS RANCH ECONODE-SECTION 25-Modification.doc
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